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April 25, 2022

Introduction

The E-Rate Central News for the Week is prepared by E-Rate Central. E-Rate Central specializes in providing consulting, compliance, and forms processing services to E-rate applicants. To learn more about our services, please contact us by phone (516-801-7804), fax (516-801-7814), or through our Contact Us web form. Additional E-rate information is located on the E-Rate Central website.

E-Rate for FY 2022:

Wave 1 for FY 2022 was issued on Saturday, April 23, 2022. In total, Wave 1 approved $1.19 billion for 17,195 applicants.  That was a major step up from the $681 million first waves in both proceeding years.

A special extended application window for new Tribal libraries closes on May 26th (see DA 22‑231 and our newsletter of March 14th).

E-Rate for FY 2021:

USAC released Wave 53 for FY 2021 on Wednesday, April 20th, for $1.93 million. Cumulative commitments stand at $2.64 billion. Nationwide, USAC has funded 98.7% of the FY 2021 applications representing 95.2% of the requested funding.

ECF for 2021-2023:

USAC issued Wave 13 on April 19th for  $37.2 million.  Cumulative ECF commitments are $4.79 billion.  Nationwide, USAC has funded 93.9% of filed applications.  Authorized disbursements as of last Friday totaled $841 million.

The third ECF application window will open on April 28th and close on May 13th.  The FCC indicates that a minimum of $1 billion will be available to fund the same type of eligible equipment and services as in the original two windows but for delivery within the 18-month span from July 1, 2022, through December 31, 2023 (albeit capped at 12 months of service for internet access).  For details, see DA 22-309, our newsletter of March 28th, and the FAQs in USAC’s ECF newsletter of March 29th.

As we approach the end of the first ECF school year, schools need to begin thinking about what they are going to be doing with ECF-funded devices and home internet services that were provided to students who will be leaving their schools at the end of the current term.  Although no guidance has yet been received from USAC, we assume and suggest the following:

  • Connected devices that had been loaned to soon to be ex-students must be returned to the schools to be repurposed for students entering the schools next year or otherwise newly eligible.  This process is not unlike how schools currently handle devices loaned to students for in-school use.  Devices used at home, however, may require additional refurbishing and testing.  Schools that have properly inventoried ECF-funded devices by student name, model number, and serial number should similarly record their return and disposition.

In theory, returned and reissued devices should reduce the need for new ECF funding in the third window.  In reality, we suspect that a not insignificant number of devices used at home, not necessarily by soon-to-be-graduating seniors, may have been lost or damaged beyond repair.  At some point — before, during, or after the ECF-3 window — USAC and/or FCC may provide guidance on the handling of lost or damaged devices for ECF purposes.  Pending such guidance, we recommend that applicants planning to request ECF‑3 funding for both (a) new students with unmet needs, and (b), existing students with device replacement needs, do so under separate FRNs.

  • Internet services for households no longer having students in the schools become ineligible for ECF funding.  Before canceling internet services for households with graduating seniors, however, schools should confirm that those families do not have any other children in the schools that would maintain their ECF service eligibility.  We recommend that internet service terminations be carefully coordinated with both the families and the ISPs.  This will be particularly important with service arrangements involving hotspots.

If ECF-funded services are being terminated for low-income households, we believe that it is incumbent on the schools to alert the affected families to the availability of $30/month internet discounts under the ACP program.  Family information on this discount program is available in the FCC’s ACP Consumer Outreach Toolkit.  The goal, perhaps coordinating with local ISPs, would be to facilitate a smooth transition from the schools’ ECF services to the families’ own discounted ACP services.

Upcoming Dates:

April 26     First of USAC’s three upcoming ECF information sessions (see ECF Newsletter below).
April 27 Comments due on the FCC’s proposal to create an E-rate competitive bidding portal (FCC 21-124).  Reply comments are due May 27th.
April 28 Opening of the third ECF application window (see DA 22-309 and our newsletter of March 28th).  The window will close May 13th at 11:59 p.m. EDT.
April 29 Form 486 deadline for FY 2021 covering funding committed in Wave 38.  More generally, the Form 486 deadline is 120 days from the FCDL date or from the service start date (typically July 1st), whichever is later.  Upcoming Form 486 deadlines are:
Wave 39            05/06/2022
Wave 40            05/13/2022
Wave 41            05/20/2022
May 16 FCC comments due on the FCC’s Notice of Inquiry regarding the prevention and elimination of digital discrimination (FCC 22-21).  Reply comments are due June 30th.
May 26 Extended FY 2022 application window deadline for new Tribal libraries (see DA 22-231).

ECF Payment Reviews:

A unique feature of ECF invoicing, not found in the E-rate program, is the option for applicants to request BEAR payments before they pay their suppliers.  Applicants choosing this option are then given 30 days after receipt of their BEAR payments to pay those suppliers.

This prepayment option appears in the BEAR form as follows:

Prepayment option appears in the BEAR form

If an applicant selects “Y,” the prepayment option, the applicant will then have to document the subsequent payment to the supplier.  If that is not done within about 35 days of the BEAR approval — 5 days to receive the Treasury payment plus 30 days to pay the supplier — USAC will email the applicant an “Emergency Connectivity Fund Information Request” stating:

USAC will email the applicant an 'Emergency Connectivity Fund Information Request'

If an applicant selects “N,” indicating that the supplier has already been paid, there is an option to upload payment documentation, thus avoiding a subsequent payment review.

EPC Entity Profiles to Be Unlocked May 1st:

Entity profiles in EPC were locked a few days prior to the opening of the FY 2022 Form 471 application window and typically remain locked for several weeks after the close of the window.  As we have discussed in the past, the purpose of locking the entity profiles during the Form 471 filing period is to prevent changes in one entity’s data that might affect applications being filed by other related entities such as a consortium or library.  Applicants trying to change their entity profiles now will receive the following message:

EPC Entity Profiles to Be Unlocked May 1st

As indicated in the current message, entity profiles are scheduled to be unlocked on May 1st.  Applicants planning to file ECF requests in the third window — April 28th to May 13th — should review their entity profiles to make sure that their discount rate data, particularly their NSLP percentages, are updated.  With limited funding available in ECF-3, discount and NSLP data will be critical.

USAC’s Emergency Connectivity Fund Program Newsletter of April 19, 2022, includes no new information not found in last week’s newsletter.  As a useful reminder, however, USAC again listed the three new information and “office hours” sessions dealing with the upcoming ECF Window 3 application period.

  • Tuesday, April 26 at 3:00 p.m. EDT: ECF Window 3 Information Session –  Register
  • Tuesday, May 3 at 3:00 p.m. EDT: ECF Window 3 Office Hours –  Register
  • Tuesday, May 10 at 3:00 p.m. EDT: ECF Window 3 Office Hours –  Register

USAC’s Schools and Libraries News Brief of April 22, 2022, discusses a series of E-rate topics primarily related to the FY 2022 application window, including the following:

  • The biggest news, mentioned only in one sentence at the top of Page 2, was that USAC was releasing FY 2022 Wave 1 on Friday, April 22nd, with FCDLs to be sent on Saturday (see Wave 1 funding summary above).
  • The Form 473 (Service Provider Annual Certification (“SPAC”) Form) is now available for FY 2022.  The updated SPAC includes two new national security certifications attesting to compliance with the FCC’s supply chain rules.
  • Numerous post-application reminders are provided for:
    • Checking submitted applications
    • Understanding the PIA review process
    • Submitting RAL modification requests and post-commitment corrections
    • Filing a Form 486 after an application has been approved
  • The FY 2022 Form 471 application deadline for new tribal libraries is May 26th.